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Home My WebLink About14-2196 c�, z r � t For Prothonotary Use Only: ' ` §' ,iprem�e, Court.of Pe�nnsylvani�r. C0!U `'. C oun t y Docket No. The information collected on this form is used solely for court administration purposes. This form does not supplement or replace the filing and service ofpleadings or other papers as required by law or rules of court. Commencement of Action: S ® Complaint ❑ Writ of Summons ❑ Petition E ❑ Transfer from Another Jurisdiction ❑ Declaration of Taking ' C Lead Plaintiffs Name: Wells Fargo Bank, N.A. Lead Defendants Name: Linda C. Jumper T I Are there money damages requested? ❑ Yes ® No Dollar Amount Requested: ❑ within arbitration limits Q (check one) ❑ outside arbitration limits N Is this a Class Action Suit? ❑ Yes ® No Is this an MDJAppeal? []Yes ® No A Name of Plaintiff /Appellant's Attorney: McCabe, Weisberg & Conway, P.C. ❑ Check here if you have no attorney (a Self - Represented JPro Se] Litigant) Nature of the Case: Place an "X" to the left of the ONE case category that most accurately describes your PRIMARY CASE. If you are making more than one type of claim, check the one that you consider most important. TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS • Intentional ❑ Buyer Plaintiff Administrative Agencies • Malicious Prosecution ❑ Debt Collection: Credit Card P Board of Assessment ❑ Motor Vehicle ❑ Debt Collection: Other ❑ Board of Elections ❑ Nuisance ❑ Department of Transportation ❑ Premises Liability (does not include ❑ Statutory Appeal: Other S mass tort) E ❑ Slander/Libel/ Defamation ❑ Employment Dispute: ❑ Other: Discrimination C ❑ Employment Dispute: Other ❑ Zoning Board F T ❑ Other � I I O ❑ Other N MASS TORT ❑ Asbestos ❑ Tobacco ❑ Toxic Tort - DES ❑ Toxic Tort - Implant REAL PROPERTY MISCELLANEOUS I3 ❑ Toxic Waste ❑ Ejectment ❑ Common Law /Statutory Arbitration ❑ Other: ❑ Eminent Domain /Condemnation ❑ Declaratory Judgment ❑ Ground Rent ❑ Mandamus ` ❑ Landlord/Tenant Dispute ❑ Non - Domestic Relations ® Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABILITY Mortgage ❑ Mort a e Foreclosure: Commercial 13 Quo Warranto ❑ Dental ❑ Partition ❑ Replevin • Legal ❑ Quiet Title ❑ Other: • Medical ❑ Other: • Other Professional: Updated 1/1/2011 McCABE, WEISBERG & CONWAY, P.C. Attorneys for Plaintiff BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID # 74770 MARISA J. COHEN, ESQUIRE - ID # 87830 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LAMANNA, ESQUIRE - ID # 310321 =` ANN E. SWARTZ , ESQUIRE - ID # 201926 JOSEPH F. RIGA, ESQUIRE - ID # 57716 ^} r c JOSEPH I. FOLEY, ESQUIRE - ID # 314675' -. CELINE P. DERKRIKORIAN, ESQUIRE - ID # 313673 v ;� JENNIFER L. WUNDER, ESQUIRE - ID # 315954 ';7 KRAVETS, ESQUIRE - ID # 316421 = G CAROL A. DiPRINZIO, ESQUIRE - ID # 316094 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 (215) 790 -1010 _ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION 3476 Stateview Boulevard Fort Mill, SC 29715 No.: 1 . d 01 U Plaintiff, V. Linda C. Jumper 309 Sandbank Road Mount Holly Springs, PA 17065 Defendant. CIVIL ACTION - COMPLAINT IN MORTGAGE FORECLOSURE And now comes Wells Fargo Bank, N.A., by its attorneys, McCabe, Weisberg & Conway, P.C. and files this Complaint in Mortgage Foreclosure as follows: �' n �163,x 0 t—# 062 -PA -V4 File #78476 NOTICE AVISO You have been sued in court. If you wish to Le han demandado a usted en la corte. Si defend against the claims set forth in the usted quiere defenderse de estas demandas following pages, you must take action within ex- puestas en las paginas siguientes, usted twenty (20) days after this complaint and tiene veinte (20) dias de plazo al partir de la notice are served, by entering a written fecha de la demanda y la notificacion. Hace appearance personally or by attorney and falta asentar una comparencia escrita o en filing in writing with the court your defenses persona o con un abogado y entregar a la corte or objections to the claims set forth against en forma escrita sus defensas o sus objeciones you. You are warned that if you fail to do so a las demandas en contra de su persona. Sea the case may proceed without you and a avisado que si usted no se defiende, la corte judgment may be entered against you by the tomara medidas y puede continuar la demanda court without further notice for any money en contra suya sin previo aviso o notification. claimed in the complaint or for any other Ademas, la corte puede decidir a favor del claim or relief requested by the plaintiff. You demandante y requiere que usted cumpla con may lose money or property or other rights todas las provisiones de esta demanda. Usted important to you. puede perder dinero o sus propiedades u otros derechos importantes para usted. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU USTED LE DEBE TOMAR ESTE DO NOT HAVE A LAWYER, GO TO OR PAPEL A SU ABOGADO TELEPHONE THE OFFICE SET FORTH INMEDIATAMENTE. SI USTED NO TIENE BELOW. THIS OFFICE CAN PROVIDE A UN ABOGADO, VA A O TELEFONEA YOU WITH INFORMATION ABOUT LA OFICINA EXPUSO ABAJO. ESTA HIRING A LAWYER. OFICINA LO PUEDE PROPORCIONAR IF YOU CANNOT AFFORD TO CON INFORMATION ACERCA DE HIRE A LAWYER, THIS OFFICE MAY BE EMPLEAR A UN ABOGADO. ABLE TO PROVIDE YOU WITH SI USTED NO PUEDE INFORMATION ABOUT AGENCIES THAT PROPORCIONAR PARA EMPLEAR UN MAY OFFER LEGAL SERVICES TO ABOGADO, ESTA OFICINA PUEDE SER ELIGIBLE PERSONS AT A REDUCED FEE CAPAZ DE PROPORCIONARLO CON OR NO FEE. INFORMACION ACERCA DE LAS AGENCIAS QUE PUEDEN OFRECER LOS Cumberland County Bar Association SERVICIOS LEGALES A PERSONAS 32 South Bedford Street ELEGIBLES EN UN HONORARIO Carlisle, PA 17013 REDUCIDO NI NINGUN HONORARIO. (800) 990 -9108 Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (800) 990 -9108 062 -PA -V4 File #78476 This is a communication from a debt collector who is attempting to collect a debt, and any information obtained will be used for that purpose. Please Note: (1) unless, within thirty (30) days after your receipt of this notice, you dispute the validity of the debt, or any portion of the debt, we will assume that the debt is valid; (2) if you notify us in writing within thirty (30) days of your receipt of this notice that the debt, or a portion of the debt, is disputed, we will cease collection of the debt until we obtain verification of the debt or a copy of the judgment against you and mail to you a copy of the verification or judgment that we obtain; (3) upon your written request to us within thirty (30) days of your receipt of this notice for the name and address of the original creditor of your debt, we will cease collection of the debt until we mail to you the name and address of the original creditor, if different from the current creditor. Case Name: Wells Fargo Bank, N.A. v. Linda C. Jumper Cumberland County 062 -PA -V4 File #76476 1. The Plaintiff is Wells Fargo Bank, N.A., at 3476 Stateview Boulevard, Fort Mill, SC 29715 (hereinafter "Plaintiff'). 2. The Defendant is Linda C. Jumper, with a last known address of 309 Sandbank Road, Mount Holly Springs, PA 17065. 3. In order to protect the borrower's privacy, certain personal information of the borrower (such as loan account, Social Security numbers and birth dates), may have been partially or completely redacted on the exhibits to this Complaint. 4. Wells Fargo Bank, N.A., directly or through an agent, has possession of the Promissory Note. Wells Fargo Bank, N.A. is either the original payee of the Promissory Note or the Promissory Note has been duly indorsed. A copy of said Promissory Note is marked as Exhibit "A ", attached hereto and made a part hereof. 5. On or about May 14, 2009, Linda C. Jumper and Ronald E. Jumper, made, executed and delivered to Wells Fargo Bank, N.A. a Mortgage in the original principal amount of $153,000.00 on the premises described in the legal description marked as Exhibit `B ", attached hereto and made a part hereof. Said Mortgage being recorded in the Office of the Recorder of Cumberland County on June 11, 2009 as Instrument Number 200919727. The Mortgage is a matter of public record and is incorporated herein by reference in accordance with Pa.R.C.P. 1019(g), which rule relieves the Plaintiff from its obligation to attach documents to pleadings if those documents are of public record. 6. Plaintiff is the current Mortgagee. 7. Linda C. Jumper and Ronald E. Jumper are the record and real owner(s) of the aforesaid mortgaged premises. 062 -PA -V4 File #78476 8. Ronald E. Jumper died on June 25, 2011 leaving title vested solely in Linda C. Jumper by operation of law. 9. Defendant is in default under the terms of the aforesaid Mortgage for, inter alia, failure to pay the installments of principal and interest due June 1, 2013. 10. As of 03/21/2014 the amount due and owing Plaintiff on the mortgage is as follows: Principal $ 143,453.24 Interest From 05/01/2013 to 03/21/2014 $ 6,370.22 Late Charges $ 41.07 Escrow Advance $ 1,660.21 Property Inspections $ 0.00 Property Preservation $ 0.00 BPO /Appraisal $ 0.00 Escrow Balance $ 0.00 Corporate Advance Credit $ 0.00 Total $ 151,524.74 plus interest and all other additional amounts authorized under the Mortgage and Pennsylvania Law, actually and reasonably incurred by Plaintiff, including but not limited to, costs (including escrow advances) and Plaintiff s attorneys' fees and expenses. Plaintiff reserves the right to file a motion in the above - captioned action to add such additional sums authorized under the Mortgage and Pennsylvania Law to the above amount due and owing when incurred. 11. Notice of Intention to Foreclose as set forth in Act 6 of 1974, Notice of Homeowner's Emergency Mortgage Assistance Program pursuant to Act 91 of 1983, as amended in 2008, and /or Notice of Default as required by the mortgage document, as applicable, have been sent to Defendant. 12. This is an in rem action only against the aforesaid mortgaged premises. Plaintiff is not seeking a judgment of personal liability against the Defendant, but reserves its right to do so in a separate legal action if such right exists. If Defendant has received a discharge of personal liability in a bankruptcy proceeding, this action is in no way an attempt to re- establish such liability. 062 -PA -V4 File #78476 WHEREFORE, Plaintiff demands an in rem judgment in mortgage foreclosure for the amount due of $ 151,524.74 with interest thereon plus additional costs (including additional escrow advances), additional attorneys' fees and costs and for foreclosure and sale of the mortgaged premises. McCABE WEISBERG & C .C. B. -�,�. [ e'rrence J. McCabe, Esquire [ ] Marc S. Weisberg, Esquire [ ] Edward D. Conway, Esquire [ ] Margaret Gairo, Esquire [ ] Andrew L. Markowitz, Esquire [ ] Heidi R. Spivak, Esquire [ ] Marisa J. Cohen, Esquire [ ] Christine L. Graham, Esquire [ ] Brian T. LaManna, Esquire [ ] Ann E. Swartz, Esquire [ ] Joseph F. Riga, Esquire [ ] Joseph I. Foley, Esquire [ ] Celine P. DerKrikorian, Esquire [ ] Jennifer L. Wunder, Esquire [ ] Lena Kravets, Esquire [ ] Carol A. DiPrinzio, Esquire Attorneys for Plaintiff Dated: � ' 2014 062 -PA -V4 File #78476 VERIFICATION Denise Goldston, hereby states that he / (9 is Vice President Loan Documentation of WELLS FARGO BANK, N.A., plaintiff in this matter, that he� is authorized to make this Verification, and verify that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of his er 'nformation and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. Name: Denise Goldston Title: Vice President Loan Documentation Company: Wells Fargo Bank, N.A. Date: 03/24/2014 i 4 086 -PA -V2 File #:78476 h,b A EXHIBIT A NOTE MAY 14, 2009 (Date) [City] [State] 309 SANDBANK ROAD, MT HOLLY SPRINGS, PA 17065 [Property Address] 1. BORROWER'S PROMISE TO PAY In return for a loan that I have received, I promise to pay U.S. $ * * ** *153 , 000.00 (this. amount is called "Principal "), plus interest, to the order of the Lender. The Lender is WELLS FARGO BANK, N.A. I will make all payments under this Note in the form of cash, check or money order. I understand that the Lender may transfer this Note. The Lender or anyone who takes this.Note by transfer and who is entitled to receive payments under this Note is called the "Note Holder." 2. INTEREST Interest will be charged on unpaid principal until the full amount of Principal has been paid..I will pay interest at a yearly rate of 5.000 . %. The interest rate required by this Section 2 is the rate I• will pay both before and after any default described in Section 6(B) of this Note. j 3. PAYMENTS (A) Time and Place of Payments I will pay principal and interest by making a payment every month. I will make my monthly payment on the FIRST day of each month beginning onJULY 01, 2009 I will make these payments every month until I have paid all of the principal and interest and any other charges described below that I may owe under this Note. Each monthly payment will be applied as of its scheduled due date and will be applied to interest before Principal. If, on JUNE 01, 2039 , I still owe amounts under this Note, I will, pay those amounts in full on that date, which is called the "Maturity Date." I will make my monthly payments at WELLS FARGO HOME MORTGAGE, P.O. BOX 11701, NEWARK, NJ 071014701 or at a different place if required by the Note Holder. (B) Amount of Monthly Payments My monthly payment will be in the amount of U.S. $ * ** *821.3 4. BORROWER'S RIGHT TO PREPAY I have the right to make payments of Principal at any time before they are due. A payment of Principal only is known as a "Prepayment." When I make a Prepayment, I will tell the Note Holder in writing that I am doing so. I may not designate a payment as a Prepayment if I have not made all the monthly payments due under the Note. I may make a full Prepayment or partial Prepayments without paying a Prepayment charge. The Note Holder will use my Prepayments to reduce the amount of Principal that I owe under this Note. However, the Note Holder may apply my Prepayment to the accrued ,and unpaid interest on the Prepayment amount, before applying my Prepayment to reduce the Principal amount of the Note. If I make a partial Prepayment, there will be no changes in the due date or in the amount of my monthly payment unless the Note Holder agrees in writing to those changes. W 0 110M Kluwar Financial bervIce3 MULTISTATE FIXED RATE NOTE - Single Family - Fannie MaelFreddie Mac UNIFORM INSTRUMENT Form 3200 1101 VMP a L / VMPSN ag o 1 of NMFL 3200 (CNOT) Rev 312009 Initials: �I f. ✓ Page 1 of 3 5. LOAN CHARGES If a law, which applies to this loan and which sets maximum loan charges, is finally interpreted so that the interest or other loan charges collected, or to be collected in connection with this loan exceed the permitted limits, then: (a) any such loan charge shall be reduced by the amount necessary to reduce the charge to the permitted limit; and (b) any sums already collected from me which exceeded permitted limits will be refunded to me. The Note Holder may choose to make this refund by reducing the Principal I owe under this Note or by making a direct payment to me. If a refund reduces Principal, the reduction will be treated as a partial Prepayment. 6. BORROWER'S FAILURE TO PAY AS REQUIRED (A) Late Charge for Overdue Payments If the Note Holder has not received the full amount of any monthly payment by the end of 15 calendar days after the date it is due, I will pay a late charge to the Note Holder. The amount of the charge will be 5.000 % of my overdue payment of principal and interest. I will pay this late charge promptly but only once on each late payment. (B) Default If I do not pay the full amount of each monthly payment on the date it is due, I will be in default. (C) Notice of Default If I am in default, the Note Holder may send me a written notice telling me that if I do not pay the overdue amount by a certain date, the Note Holder may require me to pay immediately the full amount of Principal which has not been paid and all the interest that I owe on that amount. That date must be at least 30 days after the date on which the notice is mailed to me or delivered by other means. (D) No Waiver By Note Holder Even if, at a time when I am in default, the Note Holder does not require me to pay immediately in full as described above, the Note Holder will still have the right to do so if I am in default at a later time. (E) Payment of Note Holder's Costs and Expenses If the Note Holder has required me to pay immediately in full as described above, the Note Holder will have the right to be paid back by me for all of its costs and expenses in enforcing this Note to the extent not prohibited by applicable law. Those expenses include, for example, reasonable attorneys' fees. 7. GIVING OF NOTICES Unless applicable law requires a different method, any notice that must be given to me under this Note will be given by delivering it or by mailing it by first class mail to me at the Property Address above or at a different address if I give the Note Holder a notice of my different address. Any notice that must be given to the Note Holder under this Note will be given by delivering it or by mailing it by first class mail to the Note Holder at the address stated in Section 3(A) above or at a different address if I am given a notice of that different address. 8. OBLIGATIONS OF PERSONS UNDER THIS NOTE If more than one person signs this Note, each person is fully and personally obligated to keep all of the promises made in this Note, including the promise to pay the full amount owed. Any person who is a guarantor, surety or endorser of this Note is also obligated to do these things. Any person who takes over these obligations, including the obligations of a guarantor, surety or endorser of this Note, is also obligated to keep all of the promises made in this Note. The Note Holder may enforce its rights under this Note against each person individually or against all of us together. This means that any one of us may be required to pay all of the amounts owed under this Note. 9. WAIVERS I and any other person who has obligations under this Note waive the rights of Presentment and Notice of Dishonor. "Presentment" means the right to require the Note Holder to demand payment of amounts due. "Notice of Dishonor" means the right to require the Note Holder to give notice to other persons that amounts due have not been paid. MULTISTATE FIXED RATE NOTE - Single Family - Fannie Mae/Freddie Mac UNIFORM INSTRUMENT Farm 3200 1101 VMP 0 VMP5N (D80T.00 Wolters Kluwer Financial Services Initials: �� ' Page 2 of 3 10. UNIFORM SECURED NOTE This Note is a uniform instrument with limited variations in some jurisdictions. In addition to the protections given to the Note Holder under this Note, a Mortgage, Deed of Trust, or Security Deed (the "Security Instrument "), dated the same date as this Note, protects the Note Holder from possible losses which might result if I do not keep the promises which I make in this Note. That Security Instrument describes how and under what conditions I may be required to make immediate payment in full of all amounts I owe under this Note. Some of those conditions are described as follows; Iw , l � If all or any part of the Property or any Interest in the Property is sold or' jVWq* (or orroV erns not a natural person and a beneficial interest in Borrower is sold or transferred) without Lender s prior AVen consent Lender 't. R may require immediate payment re a ment in full of all sums secINA"r'h It' 'SWb t. t> . rl Y r a, However this option shall not be exercised by Lender if such exercise» is- prohebited`byi ' p libab }} 1e y ; { If Lender exercises this option, Lender shall give Borrower noticelr©flaC iliterajjt ; The;, oe Nhltl provide a period of not less than 30 days from the date the notice is given in accordance with 'Section 15 within which Borrower must pay all sums secured by this Security Instrument. If Borrower fails to pay these sums prior to the expiration of this period, Lender may invoke any remedies permitted by this Security Instrument without further notice or demand on Borrower. WITNESS THE HAND(S) AND SEAL(S) OF THE UNDERSIGNED. "v 4 (Scat) (Seal) RONALD E JUMP - Borrower LINDA C JUMPER - Borrower (Seal) (Seal) - Borrower - Borrower (Seal) (Seal) - Borrower - Borrower A (Seal) (Seal) - Borrower - Borrower (Sign Original Only] MULTISTATE FIXED RATE NOTE - Single Family - Fannie Maw7reddie Mac UNIFORM INSTRUMENT Form 3200 1101 VMP ® VMPSN Page age3).00 Wolters Kluwer Financial Services 3 of 3 ply THE oaoER OF �AN40 t M BY M: 1 Preside r Stewart Title Guaranty Company Commitment Number: SCHEDULE C PROPERTY DESCRIPTION The land referred to in this Commitment is described as follows: TRACT #1 ALL THAT CERTAIN tract of land with improvements thereon erected situate in South Middleton Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point in the center line of Township Road T-473, said point being a spike in the center line of West Pine Street Extended, said point also being North 82 degrees 30 minutes West, 25 feet from the line of land now or formerly of Russell S. Starner; thence along said (and now or formerly of Russell S. Starner, South 2 degrees 23 minutes East, 200 feet to a stake at line of land now or formerly of Samuel C. Garonzik, et al; thence along the latter. North 82 degrees 30 minutes West, 100 feet to a stake; thence still along the same, North 2 degrees 23 minutes West. 200 feet to a spike in the center line of Township Road T473 (West Pine Street Extended); thence along the latter, South 82 degrees 30 minutes East, 100 feet to a spike, the place of BEGINNING. CONTAINING .452 acres according to a survey of Thomas A. Neff, R. S., dated October 24, 1969. BEING improved with a five -room ranch type dwelling and carport, known as 309 Sandbank Road, Mount Holly Springs, Pennsylvania. TRACT #2 ALL THAT CERTAIN tract of land situate in South Middleton Township, Cumberland County, Pennsylvania, bounded and described in accordance with a survey by Carl David Bert, Registered Surveyor, dated March 11, 1983, and recorded in the Office of the Recorder of Deeds in and for Cumberland County in Plan Book 43, Page 27, and being Lot No. 3B as shown on said Plan, as follows: BEGINNING at an existing iron pin at the Southwest corner of land now or formerly of Herbert J. George and Cathrine B. George, which point is also on the dividing line between Lot No. 3A and 3B on said Plan; thence along said dividing line between Lot No 3B and land of Herbert J. George and Cathrine B. George, South 88 degrees 45 minutes 04 seconds East, a distance of 100 feet to an existing iron pin on the dividing line between Lot No. 313 and 3C as it appears on said Plan; thence along said dividing line, South 08 degrees 59 minutes 37 seconds East, a distance of 25 feet to an iron pin in line of Lot No. 3A; thence along the dividing line between Lot Nos. 3B and 3A, North 88 degrees 45 minutes 04 seconds West, a distance of 100 feet to an iron pin; thence continuing along Lot No. 3A, North 08 degrees 59 minutes 37 seconds West, a distance of 25 feet to an existing iron pin, the place of BEGINNING. Parcel #40- 32- 2334 -054 ALTA Commitment Schedule C �� FORM I Wells :Fargo Bank, N.A. IN THE COURT OF COMMON PLEAS. OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA, VS. Linda C. Jumper Civil Defendants . NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE DIVERSION PROGRAM You have been served with a foreclosure complaint that could cause you to lose your home. If you own and live in the residential property which is the subject of this foreclosure action, you may be able to participate in a court- supervised conciliation conference in an effort to resolve this matter with your lender. If you do not have a lawyer, you must take the following steps to be eligible for a conciliation conference. First, within twenty (20) days of your receipt of this notice, you must contact MidPenn Legal Services at (717) 243 -9400 extension 2510 or (800) 822 -5288 extension 2510 and request appointment of a legal representative at no charge to you. Once you have been appointed a legal representative, you must promptly meet with that legal representative within twenty (20) days of the appointment date. During that meeting, you must provide the legal representative with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your legal representative complete a financial worksheet in the format attached hereto, the legal representative will prepare and file a Request for Conciliation Conference with the Court, which must be filed with the Court within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. If you are represented by a lawyer, you and your lawyer must take the following steps to be eligible for a conciliation conference. It is not necessary for you to contact MidPenn Legal Service for the appointment of a legal representative. However, you must provide your lawyer with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your lawyer complete a financial worksheet in the format attached hereto, your lawyer will prepare and file a Request for Conciliation Conference with the Court, which must be filed with the Court within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. IF YOU WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE. Respectfull s itted: Date [Signature of Counsel for Plaintiff] 78476 Page 1 Y M FORM 2 Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet Date: Cumberland County Court of Common Pleas Docket # BORROWER REQUEST FOR HARDSHIP ASSISTANCE To complete your request for hardship assistance, your lender must consider your circumstances to determine possible options while working with your Please provide the following information to the best of your knowledge: CUSTOM Borrower name(s): Property Address: City: State: Zip: Is the property for sale? Yes ❑ No ❑ Listing date: Price $ Realtor Name: Realtor Phone: Borrower Occupied? Yes ❑ No ❑ Mailing Address (if different): City: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: # of people on household: How long? CO-BORROWER Mailing Address (if different): City: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: # of people on household: How long? INFORMATION FINANCIAL First Mortgage Lender: Type of Loan: Loan Number: Date You Closed Your Loan: Second Mortgage Lender: Type of Loan: Loan Number: Total Mortgage Payment Amount $ Included Taxes & Insurance: Date of Last Payment: Primary Reason for Default: Is the loan in Bankruptcy? Yes ❑ No ❑ If yes, provide names, location of court, case number & attorney: Assets Amount Owed: Value Home: $ $ Other Real Estate: $ $ Retirement Funds: $ $ Investments: $ $ Checking: $ $ Savings: $ $ Other: $ $ Automobile #1: Model: Year: Amount owed: Value: Automobile #2: Model: Year: Amount owed: Value: Other transportation (automobiles, boats, motorcycles): Model Year: Amount owed: Value: Monthly Income Name of Employers: 1. 2. 3. Additional Income Description (not wages): 1. monthly amount: 2. monthly amount: Borrower Pay Days: Co- Borrower Pay Days: Monthly Expenses: (Please only include expenses you are currently paying) EXPENSE AMOUNT EXPENSE AMOUNT Mortgage Food 2 "d Mortgage Utilities Car Payment(s) Condo/Neigh. Fees Auto Insurance Med. (not covered) Auto fuel/repairs Other prop. payment Install. Loan Payment Cable TV Child Support/Alim. Spending Money Da /Child Care /Tuft. Other Expenses Amount Available for Monthly Mortgage Payments Based on Income & Expenses: Have you been working with a Housing Counseling Agency? Yes ❑ No ❑ If yes, please provide the following information: Counseling Agency: Counselor: Phone (Office): Fax: 2 • Email: Have you made application for Homeowners Emergency Mortgage Assistance Program (HEMAP) assistance? Yes ❑ No ❑ If yes, please indicate the status of the application: Have you had any prior negotiations with your lender or lender's loan servicing company to resolve your deliquency? Yes ❑ No ❑ If yes, please indicate the status of those negotiations: Please provide the following information, if known, regarding your lender or lender's loan servicing company: Lender's Contact (Name): Phone: Servicing Company (Name): Contact: Phone: I/We, , authorize the above named to use /refer this information to my lender /servicer for the sole purpose of evaluating my financial situation for possible mortgage options. I /We understand that I/we am/are under no obiligation to use the services provided by the above named Borrower Signature Date Co- Borrower Signature Date Please forward this document along with the following information to lender and lender's counsel: Proof of income Past 2 bank statements Proof of any expected income for the last 45 days Copy of a current utility bill Letter explaining reason for delinquency and any supporting documentation (hardship letter) Listing agreement (if property is currently on the market) 3 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY ILEU-UFF! U- THE PROTHONG TAS:, 2014 MAY -8 PM 2:54 CUMBERLAND COUNTY PENNS YLVANIA Wells Fargo Bank, N.A. vs. Linda C Jumper Case Number 2014-2196 SHERIFF'S RETURN OF SERVICE 05/01/2014 03:04 PM - Chief Deputy Jody S. Smith served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by "personally" handing a true copy to a person representing themselves to be the Defendant, to wit: Linda C Jumper at the Cumberland County Sheriffs Office, One Courthouse Square, Carlisle, PA 17013. The defendant now resides at 226 Chestnut Street, Mt. Holly Springs, PA 17065 and is in the process of removing all personal property from the mortgaged residence. JODY S. SMITH, DEPUTY SHERIFF COST: $35.91 SO ANSWERS, May 06, 2014 RON R ANDERSON, SHERIFF (c) CountySuite Sheriff, Teleosoft. Inc. McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. MCCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID # 74770 MARISA J. COHEN, ESQUIRE - ID # 87830 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LAMANNA, ESQUIRE - ID # 310321 ANN E. SWARTZ, ESQUIRE - ID # 201926 JOSEPH F. RIGA, ESQUIRE - ID # 57716 JOSEPH I. FOLEY, ESQUIRE - ID # 314675 CELINE P. DERKRIKORIAN, ESQUIRE - ID # 313673 JENNIFER L. WUNDER, ESQUIRE - ID # 315954 LENA KRAVETS, ESQUIRE - ID # 316421 CAROL A. DiPRINZIO, ESQUIRE - ID # 316094 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 215 790-1010 Wells Fargo Bank, N.A. Plaintiff Linda C. Jumper v. Defendant ASSESSMENT OF DAMAGES AND ENTRY OF JUDGMENT TO THE PROTHONOTARY: Kindly enter judgment by default in favor of Plaintiff and against Defendant, Linda C. Jumper, in the above - captioned matter for failure to answer Complaint as required by Pennsylvania Rules of Civil Procedure, and assess damages as follows: Principal $ 151,524.74 Interest from 03/22/2014 to 06/02/2014 $ N/A Total Attorneys for Plaintiff PHD THONO TAR., 2014 JUN -3 AN 23 CUMBERLAND COUNTY PENNSYLVANIA CUMBERLAND COUNTY COURT OF COMMON PLEAS Number 14-2196 $ 151,524.74 McCABE, . "I RG & CONWAY, P.C. BY: [ ] Terrence J.!►[� a ' -, sq. [ ] Marc S. Weisberg, Esq. [ ] Edward D. Conway, Esq. [ ] Margaret Gairo, Esq. [ ] Andrew L. Markowitz, Esq. [ ] Heidi R. Spivak, Esq. [ ] Marisa J. Cohen, Esq. [ ] Christine L. Graham, Esq. [ ] Brian T. LaManna, Esq. [ ] Ann E. Swartz, Esq. [ ] Joseph F. Riga, Esq. [ ] Joseph I. Foley, Esq. [ ] Celine P. DerKrikorian, Esq. [1] Jennifer L. Wunder, Esq. [ ] Lena Kravets, Esq. [ ] Carol A. DiPrinzio, Esq. Attorneys for Plaintiff � 4I(0.S0 pecloki 1. w oatette AND NOW, this S day of O fl P - , 2014, Judgment is entered in favor of Plaintiff, Wells12_4:v36(1040 Fargo 1' 4 i44 Bank, N.A., and against Defendant, Linda C. Jumper, in rem only and not in personam, and damages are assessed in the amount of $151,524.74, plus interest and costs. BY THE PROTH Department of Defense Manpower Data Center Results as of : Jun -02-2014 06:07:03 AM SCRA 3.0 Status Report Pursuant to Servicermernbers Civil Relief Act. Last Name: JUMPER First Name: LINDA Middle Name: C Active Duty Status As Of: Jun -02-2014 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA ~ . / 1 ' - . .4... No , Is, NA i r This response reflects where the individual left active dutystatus within 367 days preceding the Active Duty Status Date This response reflects the Individuals' active duty status based on the Active Duty Status Date r;1 • -( I Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA ] NA _ _ /' t. -�,? -... •No . `; •1I ,t NA i r This response reflects where the individual left active dutystatus within 367 days preceding the Active Duty Status Date The Member or His/Her Unit Was Notifled of a Future Call -Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Nottflcation End Date Status Service Component NA -. NA.;. `N/. .'' i• NO' -.1 NA This response reflects whether the Individual or his/her unit has received early notification to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the status of the individual on the active duty status date as to all branches of the Uniformed Seivices (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. Mary M. Snavely -Dixon, Director Department of Defense - Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act (50 USC App. § 501 et seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced only a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual was on active duty for the active duty status date, oris otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil" URL: http://www.defenselink.mil/faq/pis/PCO9SLDR.html. If you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. § 521(c). This response reflects the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2) Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d) (1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard, this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC § 502(f) for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves (TARs), Marine Corps Active Reserve (ARs) and Coast Guard Reserve Program Administrator (RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(d)(1). Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name, SSN/date of birth, and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: PAQOHC53C05COD0 IN THE UNITED STATES BANKRUPTCY COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA IN RE: LINDA CAROL JUMPER AKA LINDA JUMPER WELLS FARGO BANK, NA Debtors. Movant. and LINDA CAROL JUMPER AKA LINDA JUMPER, and CHARLES J. DEHART III, CHAPTER 13 TRUSTEE, Respondents : CASE NO.: 13-bk-03269-MDF : CHAPTER 13 ORDER OF COURT AND NOW, to wit, upon consideration of the Motion for Relief from the Automatic Stay filed by Wells Fargo Bank, NA ("Movant"), it is hereby ORDERED, ADJUDGED AND DECREED, that the Motion is granted and that the Automatic Stay be and hereby is terminated as it affects the interest of Wells Fargo Bank, NA in and to the Real Property of Debtor located at 309 Sandbank Road, Mt Holly Springs, PA 17065. Dated: October 16, 2013 Case 1:13-bk-03269-MDF Doc 25 Filed 10/16/13 Entered 10/16/13 09:09:20 Desc Main Document Page 1 of 1 District/Off: 0314-1 Case: 1:13—bk-03269—MDF Notice Recipients User: KDavis Form ID: pdfD10 Date Created: 10/16/2013 Total: 1 Recipients submitted to the BNC (Bankruptcy Noticing Center): db Linda Carol Jumper 309 Sandbank Road Mount Holly Springs, PA 17065 TOTAL: 1 Case 1:13-bk-03269-MDF Doc 25-1 Filed 10/16/13 Entered 10/16/13 09:09:20 Desc PDF - All Chatty: Notice Recipients Page 1 of 1 McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID # 74770 MARISA .1. CO'HEN, ESQUIRE - ID # 87830 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LAMANNA, ESQUIRE - ID # 310321 ANN E. SWARTZ, ESQUIRE - ID # 201926 JOSEPH F. RIGA, ESQUIRE - ID # 57716 JOSEPH I. FOLEY, ESQUIRE - ID # 314675 CELINE P. DERKRIKORIAN, ESQUIRE - ID # 313673 JENNIFER L. WUNDER, ESQUIRE - ID # 315954 LENA KRAVETS, ESQUIRE - ID # 316421 CAROL A. DiPRINZ10, ESQUIRE - ID # 316094 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 (215)790-1010 Wells Fargo Bank, N.A. Plaintiff v. Linda C. Jumper Defendant Attorneys for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS Number 14-2196 AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA: COUNTY OF PHILADELPHIA: SS. The undersigned, being duly sworn according to law, deposes and says that the Defendant, Linda C. Jumper, is not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Servicemembers Civil Relief Act, 50 U.S.C. App. §501, et seq.; and that the Defendant, Linda C. Jumper, is over eighteen (18) years of age, and resides as follows: Linda C. Jumper, 226 Chestnut Street Mount Holly Springs, PA 17065 SWORN AND SUBSCRIBED BEFORE ME THIS Z DAY OF 3—c.; 1. , 2014 NOTARY .PUBLIC COMMONWEALTH OP PENNSYLVANIAAAC SEAL MAIA UCK Notary Public City of Philadelphia, County MyCOMMisson pesMay217 McCABE, WEISBERG & CONWAY, P.C. BY: [ ] Terrence J. a q. [ ] Edward D. onwa Esq. [ ] Andrew L. Markowitz, Esq. [ ] Marisa J. Cohen, Esq. [ ] Brian T. LaManna, Esq. [ ] Joseph F. Riga, Esq. [ ] Celine P. DerKrikorian, Esq. [ ] Lena Kravets, Esq. Attorneys for Plaintiff [ ] Marc S. Weisberg, Esq. [ ] Margaret Gairo, Esq. [ ] Heidi R. Spivak, Esq. [ ] Christine L. Graham, Esq. [ ] Arm E. Swartz, Esq. [ ] Joseph I. Foley, Esq. [}C] Jennifer L. Wunder, Esq. [ ] Carol A. DiPrinzio, Esq. McCABE, WEISBERG AND CONWAY, P.C. BY; TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID # 74770 MARISA J. COHEN, ESQUIRE - ID # 87830 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LAMANNA, ESQUIRE - ID # 310321 ANN E. SWARTZ, ESQUIRE - ID # 201926 JOSEPH F. RIGA, ESQUIRE - ID # 57716 JOSEPH I. FOLEY, ESQUIRE - ID # 314675 CELINE P. DERKRIKORIAN, ESQUIRE - ID # 313673 JENNIFER L. WUNDER, ESQUIRE - ID # 315954 LENA KRAVETS, ESQUIRE - ID # 316421 CAROL A. DiPRINZIO, ESQUIRE - ID # 316094 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 (215 790-1010 Wells Fargo Bank, N.A. Plaintiff Linda C. Jumper v. Defendant AFFIDAVIT OF LAST-KNO N Attorneys for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY Number 14-2196 AILING ADDRESS OF DEFENDANT COMMONWEALTH OF PENNSYLVANIA: COUNTY OF PHILADELPHIA: The undersigned attorney for the Plaintiff in the within matter, being duly sworn according to law, hereby deposes and says that the last -known mailing address of the Defendant is: Linda C. Jumper 226 Chestnut Street Mount Holly Springs, Pennsylvania 17065 SWORN AND SUBSCRIBED BEFORE ME THIS Z DAY OF f U iI�R , 2014 NOTARY PUBL oMO AL OF NOTARIAL SEALNSYLVA Ci of INSHICK Nota ry Public Philadelphia, COMMissiM1�y tJ17 A. SS. McCABE, BERG BY: [ ] Terrence J Ca a sq. [ ] Edward D. Conway, Esq. [ ] Andrew L. Markowitz, Esq. ] Marisa J. Cohen, Esq. [ ] Brian T. LaManna, Esq. [ ] Joseph F. Riga, Esq, [ ] Celine P. DerKrikorian, Esq. [ ] Lena Kravets, Esq. Attorneys for Plaintiff CONWAY, P.C. Marc S. Weisberg, Esq. Margaret Gairo, Esq. Heidi R. Spivak, Esq. Christine L. Graham, Esq. Ann E. Swartz, Esq. Joseph I. Foley, Esq. [kj] Jennifer L. Wunder, Esq. [ ] Carol A. DiPrinzio, Esq. co. McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID # 74770 MARISA J. COHEN, ESQUIRE - ID # 87830 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LAMANNA, ESQUIRE - ID # 310321 ANN E. SWARTZ, ESQUIRE - ID # 201926 JOSEPH F. RIGA, ESQUIRE - ID # 57716 JOSEPH I. FOLEY, ESQUIRE - ID # 314675 CELINE P. DERKRI'KORIAN, ESQUIRE - ID # 313673 JENNIFER L. WUNDER, ESQUIRE - ID # 315954 LENA KRAVETS, ESQUIRE - ID # 316421 CAROL A. DiPRINZIO, ESQUIRE - ID # 316094 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 (215) 790-1010 Welts Fargo Bank, N.A. Plaintiff Linda C. Jumper v. Defendant Attorneys for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS Number 14-2196 CERTIFICATION The undersigned hereby certifies that he/she is the attorney for Plaintiff, being duly sworn according to law, deposes and says that a letter was deposited in the United States Mail notifying the Defendant that judgment would be entered against him/her/them within ten (10) days from the date of said letter in accordance with Rule 237.5 of the Pennsylvania Rules of Civil Procedure. A copy of said letter is attached hereto and marked as Exhibit "A". ON SWORN AND SUBSCRIBED BEFORE ME THIS ,2r‘ DAY OF , 2014 NOTARY-711BLI� ALTH OF P NOTARIAL SEAL MAIA KUS^HICK, Notary Publicly M CommissionaEx�ares Ma 10,21017 SY!„ vA McCABE, WE BY: [ ] Terrence J. [ ] Edward D. Conway, sq. [ ] Andrew L. Markowitz, Esq. [ ] Marisa J. Cohen, Esq. [ ] Brian T. LaManna, Esq. [ ] Joseph F. Riga, Esq. [ ] Celine P. DerKrikorian, Esq. [ ] Lena Kravets, Esq. Attorneys for Plaintiff SBERG & CON AY, P.C. Marc S. Weisberg, Esq. [ ] Margaret Gairo, Esq. [ ] Heidi R. Spivak, Esq. [ ] Christine L. Graham, Esq. [ ] Ann E. Swartz, Esq. [ ] Joseph I. Foley, Esq. [So] Jennifer L. Wunder, Esq. [ ] Carol A. DiPrinzio, Esq. VERIFICATION The undersigned attorney hereby certifies that he/she is the Attorney for the Plaintiff in the within action, and that he/she is authorized to make this verification and that the foregoing facts based on the information from the Plaintiffs representative, who is out of jurisdiction and not available to sign this verification at this time, are true and correct to the best of his/her knowledge, information and belief and further states that false statements herein are made subject to the penalties of 18 PA.C.S. §4904 relating to unsworn falsification to authorities. McCABE, WEERG & CONWAY, P.C. BY: [ ] Terrence J. be, Esq. [ ] Edward D. Conway, Esq. [ ] Andrew L. Markowitz, Esq. [ ] Marisa J. Cohen, Esq. [ ] Brian T. LaManna, Esq. [ ] Joseph F. Riga, Esq, [ ] Celine P. DerKrikorian, Esq. [ ] Lena Kravets, Esq. Attorneys for Plaintiff Wells Fargo Bank, N.A. v. Linda C. Jumper Cumberland County; Number: 14-2196 [ ] Marc S. Weisberg, Esq. [ ] Margaret Gairo, Esq. [ ] Heidi R. Spivak, Esq. [ ] Christine L. Graham, Esq. [ ] Ann E. Swartz, Esq. [ ] Joseph I. Foley, Esq. [)o] Jennifer L. Wunder, Esq. [ ] Carol A. DiPrinzio, Esq. Curt Long Prothonotary OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Courthouse, Carlisle, Pennsylvania 17013 May 22, 2014 To: Linda C. Jumper 226 Chestnut Street Mount Holly Springs, Pennsylvania 17065 Wells Fargo Bank, N.A. vs. Linda C. Jumper Cumberland County Court of Common Pleas Number 14-2196 NOTICE PURSUANT TO RULE 237.5 NOTICE OF INTENTION TO FILE PRAECIPE TO ENTER JUDGMENT BY DEFAULT IMPORTANT NOTICE You ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YQU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. You SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFF.R LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED PEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (800) 990-9108 rws NOTIFICACION IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER PRESENTADO UNA COMPARECENCIA ESCRITA, YA SEA PERSONALMENTE 0 POR ABOOADO Y POR NO HABER RADICADO POR ESCRITO CON ESTE TRIBUNAL SUS DEFENSAS U OBJECIONES A LOS RECLAMOS FORMULADOS EN CONTRA SUMO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE DIEZ (10) DIAS DE LA FECHA DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARECER USTED EN CORTE U OIR PREUBA ALOUNA, DICTAR SENTENCIA EN SU CONTRA Y USTED PODRIA PERDER DIENES U OTROS DERECHOS IMPORTANTES. USTED LE DERE TOMAR ESTE PAPEL A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE A UN ABOGADO, VA A 0 TELEFONEA LA OFICINA EXPUSO ABAJO, ESTA OFICINA LO PUEDE PROPORCIONAR CON INFORMACION ACERCA DE EMPLEAR A UN ABOGADO. SI USTED NO PUEDE PROPORCIONAR PARA EMPLEAR UN ABOGADO, ESTA OFICINA PUEDE SER CAPAZ DE PROPORCIONARLO CON INFORMACION ACERCA DE LAS AOENCIAS QUE PUEDEN OFRECER LOS SBRVICIOS LEGALES A PERSONAS ELEGIBLES EN UN HONORARIO REDUCIDO NI NINOUN HONORARIO, Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (800) 990-9108 McCABE, WEISBER G ANDCO1WAY � BY: CO [ ) Terrence J. McCabe, Esquire [ ] Edward D. Conway, Esquire [ ] Andrew L. Markowitz, Esquire [ ] Marisa J. Cohen, Esquire [ ] Brian T. LaManna, Esquire [ 1 Joseph F. Riga, Esquire [ ] Celine P. DerKrikorian, Esquire [ ] Lena Kravets, Esquire Attorneys for Plaintiff ci\n, c S. Weisberg, Esquire Margaret Gairo, Esquire Heidi R. Spivak, Esquire Christine L. Graham, Esquire Ann E. Swartz, Esquire Joseph I. Foley, Esquire Jennifer L. Wunder, Esquire Carol A. DiPrinzio, Esquire Curt Long Prothonotary • OFFICE OF THE PROTHONOTARY • COURT OF COMMON PLEAS Cumberland County Courthouse, Carlisle, Pennsylvania 17013 May 22, 2014 To: Linda C. Jumper 309 Sandbank Road Mount Holly Springs, Pennsylvania 17065 Welis Fargo Bank, N.A. vs, Linda C. Jumper Cumberland County Court of Common Pleas Number 14-2196 NOTICE PURSUANT TO RULE 2374 NOTICE OF INTENTION TO FILE PRAECIPE TO ENTER JUDGMENT BY DEFAULT IMPORTANT NOTICE You ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU, UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE or THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, 00 TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER, IF you CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAYBE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGF,NCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (800) 990-9108 rws NOTIFICACION IMPORTANTE USTED S6 ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER PRESENTADO UNA COMPARECENCIA ESCRITA, YA SEA PERSONALMENTE 0 POR ABOOADO Y POR NO HABER RADICA DO POR ESCRITO CON ESTE TRIBUNAL SUS DEPENSAS U OBJECIONES A LOS RECLAMOS FORMULADO$ EN CONTRA SUYO, AL NO TOMAR LA ACCION DEBIDA DENTRO DE DIU (10) DIAS DE LA FECHA DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARECER USTED EN CORTE U OIR PREUDA /MAUNA, DICTAR SENTENCIA EN SU CONTRA Y USTEDPODRIA PERDER BIENES U OTROS DERECHOS IMPORTANTES. USTED LE DEBE TOMAR ESTE PAPEL A SU ABOGADO INMEDIATAMENTE. Si USTED NO TIENE A UN ABOOADO, VA A 0 TELEFONEA LA OFICINA EXPUSO ABAJO. ESTA ()MINA LO PUEDE PROPORCIONAR CON INFORMACION ACERCA DE EMPLEAR A UN ABOOADO. SI USTED NO PUEDE PROPORCIONAR PARA EMPLEAR UN ABOOADO, ESTA OFICINA PUEDE SER CAPAZ DE PROPORCIONARLO CON INFORMACION ACERCA DE LAS AOENCIAS QUEPUEDEN OFRECER LOS SERVICIOS LEOALES A PERSONAS ELEGIBLES EN UN HONORARIO RP.DUCIDO NI NINGON HONORARIO. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (800) 990-9108 MCCABE, WEISBERG AND CONWAY, P,C. BY:. [ ] Terrence J, McCabe, Esquire ( ] Edward D. Conway, Esquire ( Andrew L. Markowitz, Esquire [ ] Marisa J. Cohen, Esquire [ ] Brian T. LaManna, Esquire ] Joseph P, Riga, Esquire ] Celine P. DerKrikorian, Esquire [ Lena Kravets, Esquire Attorneys for Plaintiff [-1-More S. Weisberg, Esquire ( Margaret Gairo, Esquire [ ] Heidi R. Spivak, Esquire [ 1 Christine L, Graham, Esquire [ Ann E. Swartz, Esquire [ 1 Joseph L Foley, Esquire [ ] Jennifer L. Wunder, Esquire [ ] Carol A. DiPrinzio, Esquire OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Courthouse Carlisle, Pennsylvania 17013 Prothonotary To: Linda C. Jumper 226 Chestnut Street Mount Holly Springs, Pennsylvania 17065 Wells Fargo Bank, N.A. Linda C. Jumper Plaintiff v. Defendant COURT OF COMMON PLEAS CUMBERLAND COUNTY No. 14-2196 NOTICE Pursuant to Rule 236, you are hereby notified that a JUDGMENT has been entered in the above proceeding as indicated below. Prothonotary X Judgment by Default Money Judgment Judgment in Replevin Judgment for Possession 3 If you have any questions concerning this Judgment, please call McCabe, Weisberg and Conway, P.C. at (215) 790-1010. OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Courthouse Carlisle, Pennsylvania 17013 Prothonotary To: Linda C. Jumper 309 Sanbank Road Mount Holly Springs, Pennsylvania 17065 Wells Fargo Bank, N.A. Linda C. Jumper Plaintiff v. Defendant COURT OF COMMON PLEAS CUMBERLAND COUNTY No. 14-2196 NOTICE Pursuant to Rule 236, you are hereby notified that a JUDGMENT has been entered in the above proceeding as indicated below. Prothonotary X Judgment by Default Money Judgment Judgment in Replevin Judgment for Possession If you have any questions concerning this Judgment, please call McCabe, Weisberg and Conway, P.C. at (215) 790-1010. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION FILE NO.: 14-2196 Civil Term Wells Fargo Bank, N.A. v. AMOUNT DUE: $151,524.74 Linda C. Jumper INTEREST: from 06/03/14 $4,583.44 at $24.91 ATTY'S COMM.: COSTS: TO THE PROTHONOTARY OF SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. PRAECIPE FOR EXECUTION Issue writ or execution in the above matter to the Sheriff of Cumberland County, for debt, interest and costs upon the following described property of the defendant(s) 309 Sandbank Road, Mount Holly Springs, Pennsylvania 17065 (More fully described as attached) PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of CUMBERLAND County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). (Indicate) Index this writ against the garnishee(s) as a lis pendens against real estate of the defendant(s) described in the attached exhibit. DATE: McCABE, WEISBERG & CONWAY, P.C. BY: [ ] Terrehce J. cCabe, Esq. [ ] Edward D. onway, Esq. [ ] Andrew L. Markowitz, Esq. [ ] Marisa J. Cohen, Esq. [ ] Brian T. LaManna, Esq. [ ] Joseph F. Riga, Esq. [ ] Celine P. DerKrikorian, Esq. [ ] Lena Kravets, Esq. Attorneys for Plaintiff ai4 c0A1- 16 3 dg GgF /01Li [ ] Marc S. Weisberg, Esq. j...--rTvlargaret Gairo, Esq. [ ] Heidi R. Spivak, Esq. [ ] Christine L. Graham, Esq. [ ] Ann E. Swartz, Esq. [ ] Joseph I. Foley, Esq. [ ] Jennifer L. Wunder, Esq. [ ] Carol A. DiPrinzio, Esq. Address:123 S. Broad Street, Suite 1400 Philadelphia, PA 19109 Attorney for: Plaintiff Telephone: (215) 790 1010 Supreme Court IDS . n -Ii.°9.2.556 Acre .Jl Fo/a `(7aaI (1 of _iss•LEt4 McCABE, WEISBERG & CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID # 74770 MARISA J. COHEN, ESQUIRE - ID # 87830 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LAMANNA, ESQUIRE - ID # 310321 ANN E. SWARTZ, ESQUIRE - ID # 201926 JOSEPH F. RIGA, ESQUIRE - ID # 57716 JOSEPH I. FOLEY, ESQUIRE - ID # 314675 CELINE P. DERKRIKORIAN, ESQUIRE - ID # 313673 JENNIFER L. WUNDER, ESQUIRE - ID # 315954 LENA KRAVETS, ESQUIRE - ID # 316421 CAROL A. DiPRINZIO, ESQUIRE - ID # 316094 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 (215) 790-1010 Wells Fargo Bank, N.A. Linda C. Jumper Plaintiff v. Defendant Attorneys for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS NO: 14-2196 AFFIDAVIT PURSUANT TO RULE 3129.1 The undersigned, attorney for Plaintiff in the above action, sets forth the following information concerning the real property located at: 309 Sandbank Road, Mount Holly Springs, Pennsylvania 17065, as of the date the Praecipe for the Writ of Execution was filed. A copy of the description of said property being attached hereto. 1. Name and address of Owner or Reputed Owner Name Linda C. Jumper Address 309 Sanbank Road Mount Holly Springs, Pennsylvania 17065 and/or 226 Chesnut Street Mount Holly Springs, Pennsylvania 17065 2. Name and address of Defendant in the judgment: Name Address Linda C. Jumper 309 Sanbank Road Mount Holly Springs, Pennsylvania 17065 and/or 226 Chesnut Street Mount Holly Springs, Pennsylvania 17065 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Plaintiff herein Curtis Johnson Address c/o George A. Michak Michak Teeter & Lewis LLC 2000 Linglestown Road, Suite 100 Harrisburg, Pennsylvania 17110 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein 5. Name and address of every other person who has any record lien on the property: Name Address NONE 6. Name and address of every other person who has any record interest in the property which may be affected by the sale: Name Address NONE 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address Tenants/Occupants 309 Sandbank Road Mount Holly Springs, Pennsylvania 17065 Commonwealth of Pennsylvania Department of Public Welfare Bureau of Child Support Enforcement P.O. Box 2675 Harrisburg, PA 17105 ATTN: Dan Richard Commonwealth of Pennsylvania Inheritance Tax Office Commonwealth of Pennsylvania Bureau of Individual Tax Inheritance Tax Division 110 North 8th Street Suite #204 Philadelphia, PA 19107 6th Floor, Strawberry Square Department #280601 Harrisburg, PA 17128 Department of Public Welfare TPL Casualty Unit Estate Recovery Program PA Department of Revenue PA Department of Revenue Bureau of Compliance Lien Section Commonwealth of Pennsylvania Department of Revenue Bureau of Compliance United States of America Domestic Relations Cumberland County Tax Claim Bureau Commonwealth of PA Department of Revenue United States of America United States of America c/o Atty General of the United States United States of America c/o Atty General of the United States Willow Oak Building P.O. Box 8486 Harrisburg, PA 17105-8486 Bureau of Compliance P.O. Box 281230 Harrisburg, PA 17128-1230 PO BOX 280948 Harrisburg PA 17128-0948 Clearance Support Department 281230 Harrisburg, PA 17128-1230 ATTN: Sheriff's Sales Internal Revenue Service Technical Support Group William Green Federal Building Room 3259 600 Arch Street Philadelphia, PA 19106 P.O. Box 320 Carlisle, PA 17013 1 Courthouse Square Carlise, PA 17013 Bureau of Compliance Department 280946 Harrisburg, PA 17128-0946 Attn: Sheriffs Sales c/o United States Attorney for the Middle District of PA Harrisburg Federal Building & Courthouse 228 Walnut Street, Ste. 220 Harrisburg, PA 17108-1754 U.S. Dept of Justice, Room 51 1 1 950 Pennsylvania Avenue NW Washington, DC 20530-0001 U.S. Dept of Justice, Room 4400 950 Pennsylvania Avenue NW Washington, DC 20530-0001 Name and address of Attorney of record: Name Address NONE I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. DATE McCABE, WEISBERG & CONWAY, P.C. BY: [ ] Terrence J jvlcCabe, Esq. [ ] Edward D. Conway, Esq. [ ] Andrew L. Markowitz, Esq. [ ] Marisa J. Cohen, Esq. [ ] Brian T. LaManna, Esq. [ ] Joseph F. Riga, Esq. [ ] Celine P. DerKrikorian, Esq. [ ] Lena Kravets, Esq. Attorneys for Plaintiff Wells Fargo Bank, N.A. v. Linda C. Jumper Cumberland County; Number: 14-2196 [ ] Marc S. Weisberg, Esq. T[..- lv1argaret Gairo, Esq. [ ] Heidi R. Spivak, Esq. [ ] Christine L. Graham, Esq. [ ] Ann E. Swartz, Esq. [ ] Joseph 1. Foley, Esq. [ ] Jennifer L. Wunder, Esq. [ ] Carol A. DiPrinzio, Esq. McCABE, WEISBERG & CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID # 74770 MARISA J. COHEN, ESQUIRE - ID # 87830 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LAMANNA, ESQUIRE - ID # 310321 ANN E. SWARTZ, ESQUIRE - ID # 201926 JOSEPH F. RIGA, ESQUIRE - ID # 57716 JOSEPH I. FOLEY, ESQUIRE - ID # 314675 CELINE P. DERKRIKORIAN, ESQUIRE - ID # 313673 JENNIFER L. WUNDER, ESQUIRE - ID # 315954 LENA KRAVETS, ESQUIRE - ID # 316421 CAROL A. DiPRINZIO, ESQUIRE - ID # 316094 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 (215) 790-1010 CIVIL ACTION LAW Wells Fargo Bank, N.A. Linda C. Jumper Attorneys for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY Number 14-2196 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY Linda C. Jumper 226 Chestnut Street Mount Holly Springs, Pennsylvania 17065 Linda C. Jumper 309 Sanbank Road Mount Holly Springs, Pennsylvania 17065 Your house (real estate) at 309 Sandbank Road, Mount Holly Springs, Pennsylvania 17065 is scheduled to be sold at Sheriffs Sale on December 3, 2014 at 10:00 a.m. in the Commissioner's Hearing Room located on the 2nd Floor of the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania 17013 to enforce the court judgment of $151,524.74 obtained by Wells Fargo Bank, N.A. against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be canceled if you pay to Wells Fargo Bank, N.A. the back payments, late charges, costs, and reasonable attorney's fees due. To find out how much you must pay, you may call McCabe, Weisberg and Conway, P.C., Esquire at (215) 790-1010. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See the following notice on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling McCabe, Weisberg and Conway, P.C., Esquire at (215) 790-1010. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due on the sale. To find out if this has happened, you may call McCabe, Weisberg and Conway, P.C. at (215) 790-1010. 4. If the amount due from the buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your real estate. A schedule of distribution of the money bid for your real estate will be filed by the Sheriff within thirty (30) days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed schedule of distribution is wrong) are filed with the Sheriff within ten (10) days after the posting of the schedule of distribution. 7. You may also have other rights and defenses, or ways of getting your real estate back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (800) 990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (800) 990-9108 SUITE 210 145 HUGUENOT STREET NEW ROCHELLE, NY 10801 (914)-636-8900 FAX (914) 636-8901 SUITE 201 216 HADDON AVENUE WESTMONT, NJ 08108 (856) 858-7080 FAX (856) 858-7020 SUITE 130 DELAWARE CORPORATE CENTER 1 ONE RIGHTER PARKWAY WILMINGTON, DE 19803 (302)409.3520 FAX 855-425-1980 Sheriffs Office 1 Courthouse Square Third Floor Carlisle, Pennsylvania 17013 LAW OFFICES McCABE, WEISBERG & CONWAY, P.C. SUITE 1400 123 SOUTH BROAD STREET PHILADELPHIA, PA 19109 (215) 790-1010 FAX (215) 790-1274 June 10, 2014 Re: Wells Fargo Bank, N.A. vs. Linda C. Jumper Cumberland County, Number 14-2196 Premises: 309 Sandbank Road, Mount Holly Springs, Pennsylvania 17065 Dear Sir or Madam: SUITE 800 312 MARSHALL AVENUE LAUREL, MD 20707 (301) 490-3361 FAX (301)490-1568 Also servicing the District of Columbia SUITE 203 722 E. MARKET STREET LEESBURG, VA 20176 (571) 449 9350 FAX: (855) 845-2585 SUITE 2506 1 HUN77NGTON QUADRANGLE MELVILLE, NY 11747 (631)812.4084 FAX: (855)845-2584 Enclosed please find 6 copies of Notice of Sheriff's Sale of Real Estate Pursuant to PA. R.C.P. 3129 relative to the above matter. Please note that our office may have more than one address for a particular Defendant at which we would like to make service attempts, and those addresses and directions as such are listed below. I would appreciate your serving the Notice upon the Defendant as follows: Linda C. Jumper, 226 Chestnut Street, Mount Holly Springs, PA 17065 • Linda C. Jumper, 309 Sanbank Road, Mount Holly Springs, PA 17065 **Kindly post the handbill to the property address: 309 Sandbank Road, Mount Holly Springs, Pennsylvania 17065. Very truly yours, /bm Enclosures Brittany Mucerino, mal Assistant McCabe, Weisberg aifd Conway, P.C. This is a communication from a debt collector. This letter may be an attempt to collect a debt and any information obtained will he used for that pin -pose. THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PA DAVID D. BUELL, PROTHONOTARY One Courthouse Square • Suite100 • Carlisle, PA • 17013 (717) 240-6195 www.ccpa.net WELLS FARGO BANK, N.A. Vs. LINDA C. JUMPER WRIT OF EXECUTION NO 14-2196 Civil Term CIVIL ACTION — LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs. in the above matter you are directed to levy upon and sell the following described property: (1) See legal description. (2) (Specifically describe personal property when judgment results from a mortgage covering both personal and real property pursuant to Section 9604(a)of the Uniform Commercial Code) NOTE: Description of property must be attached to the writ. Amount Due: $151,524.74 Interest FROM 6/3/14 $4,583.44 AT $24.91 Atty's Comm: Atty Paid: $184.66 Plaintiff Paid: Date: 6/16/14 (Seal) L.L.: 5.50 Due Prothy: $2.25 Other Costs: REQUESTING PARTY: Name: MARGARET GAIRO, ESQUIRE Address: 123 S. BROAD STREET, SUITE 1400 PHILADELPHIA, PA 19109 Attorney for: PLAINTIFF Telephone: 215-790-1010 Supreme Court ID No. 34419 David D. Buell, Prothonotar Deputy McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID # 74770 MARISA J. COHEN, ESQUIRE - ID # 87830 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LAMANNA, ESQUIRE - ID # 310321 ANN E. SWARTZ, ESQUIRE - ID # 201926 JOSEPH F. RIGA, ESQUIRE - ID # 57716 JOSEPH I. FOLEY, ESQUIRE - ID # 314675 CELINE P. DERKRIKORIAN, ESQUIRE - ID # 313673 LENA KRAVETS, ESQUIRE - ID # 316421 CAROL A. DiPRINZIO, ESQUIRE - ID # 316094 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 (215) 790-1010 Wells Fargo Bank, N.A. Plaintiff Linda C. Jumper v. Defendant FLED -OFFICE THE PrROTHO O TARP nit OCT 3 I PM 2: 20 CUMBERLAND COUNTY PENNSYLVANIA CUMBERLAND COUNTY COURT OF COMMON PLEAS Number 14-2196 AFFIDAVIT OF SERVICE The undersigned attorney for the Plaintiff in the within matter, hereby certifies that on the 28th day of October, 2014, a true and correct copy of the Notice of Sheriffs Sale of Real Property was served on all pertinent lienholder(s) as set forth in Amended Affidavit Pursuant to 3129.1 which is attached hereto. A copy of the Notice of Sheriffs Sale and certificate of mailing is also attached hereto and made a part hereof. SWORN AND SUBSCRIBED BEF OF • _, ME T 20'14 AY NOTARY PUB NOTARIAL SEAL Public BARBARA J. MOYER, No�Cl�� City of Philadelphia,Phila. �County M Commission Ex . Jan ''2018 McCABE, WEISBERG & CONWAY, P.C. BY: [ ] Tefrence J McCabe, Esquire [ ] Edward i6 Conway, Esquire [ ] Andrew L. Markowitz, Esquire [ ] Marisa J. Cohen, Esquire [ ] Brian T. LaManna, Esquire [ ] Joseph F. Riga, Esquire [ ] Celine P. DerKrikorian, Esquire [ ] Carol A. DiPrinzio, Esquire Attorneys for Plaintiff [ ] Marc S. Weisberg, Esquire L..] -Margaret Gairo, Esquire [ ] Heidi R. Spivak, Esquire [ ] Christine L. Graham, Esquire [ ] Ann E. Swartz, Esquire [ ] Joseph I. Foley, Esquire [ ] Lena Kravets, Esquire McCABE, WEISBERG & CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEID1 R. SPIVAK, ESQUIRE - ID # 74770 MARISA J. COHEN, ESQUIRE - ID # 87830 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LAMANNA, ESQUIRE - ID # 310321 ANN E. SWARTZ, ESQUIRE - ID # 201926 JOSEPH F. RIGA, ESQUIRE - ID # 57716 JOSEPH I. FOLEY, ESQUIRE - ID # 314675 CELINE P. DERKRIKORIAN, ESQUIRE - ID # 313673 LENA KRAVETS, ESQUIRE - ID # 316421 CAROL A. DiPRINZIO, ESQUIRE - ID # 316094 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 (215) 790-1010 Wells Fargo Bank, N.A. Linda C. Jumper Plaintiff v. Defendants Attorneys for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS NO: 14-2196 AFFIDAVIT PURSUANT TO RULE 3129.1 The undersigned, attorney for Plaintiff in the above action, sets forth the following information concerning the real property located at: 309 Sandbank Road, Mount Holly Springs, Pennsylvania 17065, as of the date the Praecipe for the Writ of Execution was filed. A copy of the description of said property being attached hereto. 1. Name and address of Owner or Reputed Owner Name Address Linda C. Jumper Linda C. Jumper Arthur Liebrum 309 Sanbank Road Mount Holly Springs Pennsylvania 17065 226 Chesnut Street Mount Holly Springs, Pennsylvania 17065 309 Sandbank Road Mount Holly Springs, Pennsylvania 17065 2. Name and address of Defendants in the judgment: Name Address Linda C. Jumper 226 Chestnut Street Mount Holly Springs, Pennsylvania 17065 Arthur Liebrum 309 Sandbank Road Mount Holly Springs, Pennsylvania 17065 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address Plaintiff herein Curtis Johnson c/o George A. Michak, Michak Teeter & Lewis LLC 2000 Linglestown Road, Suite 100 Harrisburg, Pennsylvania 17110 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein 5. Name and address of every other person who has any record lien on the property: Name Address NONE 6. Name and address of every other person who has any record interest in the property which may be affected by the sale: Name Address NONE 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address Tenants/Occupants Commonwealth of Pennsylvania Commonwealth of Pennsylvania Inheritance Tax Office Commonwealth of Pennsylvania Bureau of Individual Tax Inheritance Tax Division Department of Public Welfare TPL Casualty Unit Estate Recovery Program PA Department of Revenue PA Department of Revenue Bureau of Compliance Lien Section Commonwealth of Pennsylvania Department of Revenue Bureau of Compliance United States of America Domestic Relations Cumberland County Tax Claim Bureau Commonwealth of PA Department of Revenue 309 Sandbank Road Mount Holly Springs, Pennsylvania 17065 Department of Public Welfare Bureau of Child Support Enforcement P.O. Box 2675 Harrisburg, PA 17105 ATTN: Dan Richard 110 North 8th Street Suite #204 Philadelphia, PA 19107 6th Floor, Strawberry Square Department #280601 Harrisburg, PA 17128 Willow Oak Building P.O. Box 8486 Harrisburg, PA 17105-8486 Bureau of Compliance P.O. Box 281230 Harrisburg, PA 17128-1230 PO BOX 280948 Harrisburg PA 17128-0948 Clearance Support Department 281230 Harrisburg, PA 17128-1230 ATTN: Sheriffs Sales Internal Revenue Service Technical Support Group William Green Federal Building Room 3259 600 Arch Street Philadelphia, PA 19106 P.O. Box 320 Carlisle, PA 17013 1 Courthouse Square Carlise, PA 17013 Bureau of Compliance Department 280946 Harrisburg, PA 17128-0946 Attn: Sheriffs Sales United States of America United States of America c/o Atty General of the United States United States of America c/o Atty General of the United States 8. Name and address of Attorney of record: Name NONE c/o United States Attorney for the Middle District of PA William J. Nealon Federal Bldg. 235 North Washington Avenue, Ste. 311 Scranton, PA 18503 and Harrisburg Federal Building & Courthouse 228 Walnut Street, Ste. 220 Harrisburg, PA 17108-1754 U.S. Dept of Justice, Room 5111 950 Pennsylvania Avenue NW Washington, DC 20530-0001 U.S. Dept of Justice, Room 4400 950 Pennsylvania Avenue NW Washington, DC 20530-0001 Address I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. DATE McCABE, WEISBERG & CONWAY, P.C. BY: U [ ] Terrence . McCabe, Esq. [ ] Edward o . Conway, Esq. [ ] Andrew L. Markowitz, Esq. [ ] Marisa J. Cohen, Esq. [ ] Brian T. LaManna, Esq. [ ] Joseph F. Riga, Esq. [ I Celine P. DerKrikorian, Esq. [ ] Carol A. DiPrinzio, Esq. Attorneys for Plaintiff Re: Wells Fargo Bank, N.A. v. Linda C. Jumper. et al. Cumberland County; Number: 14-2196 [ ] Marc S. Weisberg, Esq. ...- Margaret Gairo, Esq. [ ] Heidi R. Spivak, Esq. [ ] Christine L. Graham, Esq. [ ] Ann E. Swartz, Esq. [ ] Joseph I. Foley, Esq. [ ] Lena Kravets, Esq. McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID # 74770 MARISA J. COHEN, ESQUIRE - ID # 87830 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LAMANNA, ESQUIRE - ID # 310321 ANN E. SWARTZ, ESQUIRE - ID # 201926 JOSEPH F. RIGA, ESQUIRE - ID # 57716 JOSEPH I. FOLEY, ESQUIRE - ID # 314675 CELINE P. DERKRIKORIAN, ESQUIRE - ID # 313673 LENA KRAVETS, ESQUIRE - ID # 316421 CAROL A. DiPRINZIO, ESQUIRE - ID # 316094 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 (215) 790-1010 Wells Fargo Bank, N.A. Plaintiff Linda C. Jumper v. Defendants COURT OF COMMON PLEAS CUMBERLAND COUNTY Number 14-2196 DATE: October 28, 2014 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNERS: Linda C. Jumper and Arthur Liebrum PROPERTY: 309 Sandbank Road, Mount Holly Springs, Pennsylvania 17065 IMPROVEMENTS: Mobile Home JUDGMENT AMOUNT: $151,524.74 The above -captioned property is scheduled to be sold pursuant to the judgment of the court caption above at the Sheriffs Sale on December 3, 2014 at 10:00 a.m. in the Commissioner's Hearing Room located on the 2nd Floor of the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania 17013. Our records indicate that you may hold a mortgage or judgments and liens on, and/or other interests in the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff not later than thirty (30) days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10) days after the filing of the schedule. If you have any questions regarding the type of lien or the effect of the Sheriffs Sale upon your lien, we urge you to CONTACT YOUR OWN ATTORNEY as WE ARE NOT PERMITTED TO GIVE YOU LEGAL ADVICE. Name and Address of Sender McCabe, Weisberg fid Conway, P.C. 123 S. Broad St., Suite 1400 Philadelphia, PA 19109 Attn: SETH HAMRICK Check type of mail or service: 0 Certified 0 Recorded DeliveryInternational (International) o COD ❑Registered 0 DeliveryConfirmation o Return Receipt for Merchandise p ❑ Express Mail o Signature Confirmation ❑ Insured Affix Stamp Hen (if issued as a certificate of mai or for additional '. copies of this bill Postmark and 1i Date of Receipt ._ ,, ti • y� ti L'r" 1c' ,,y 4.4111r. csrered r „t�i�� +_ _ q { +( t' _ Value U.S. PQSTAG ZIP 19109 02 1VV 0001377494 ...D if COD �— 'llC Fee r_ ' �� 020 40° T. 2B 2014. f _ -_— Line Article Number Addressee Name, Street and PO Address Postage Fee Handling Char - Fee H. Fee RD Fee RR Fee Wells Fargo Bank, N.A. v. Linda C. Jumper and Arthur Liebrum.. ' .� 1 Curtis Johnson c/o George A. Michak, Michak Teeter & Lewis LLC 2000 Linglestown Road, Suite 100 Harrisburg, Pennsylvania 17110 ' _a 0 "' 13 Z � .� `~cP ,` ii ?fit'..• tP ` 2 Tenants 309 Sandbank Road Mount Holly Springs, Pennsylvania 17065 \, 1l0 ''' - 3 Commonwealth of Pennsylvania Department of Public Welfare Bureau of Child Support Enforcement P.O. Box 2675 Harrisburg, PA 17105 ATTN: Dan Richard 4 Commonwealth of Pennsylvania Inheritance Tax Office 110 North 8' Street Suite #204 Philadelphia, PA 19107 5 Commonwealth of Pennsylvania Bureau of Individual Tax Inheritance Tax Division 6th Floor, Strawberry Square Department #280601 Harrisburg, PA 17128 6 Department of Public Welfare TPL Casualty Unit Estate Recovery Program Willow Oak Building P.O. Box 8486 Harrisburg, PA 17105-8486 • 7 PA Department of Revenue Bureau of Compliance P.O. Box 281230 Harrisburg, PA 17128-1230 8 ,+ PA Department of Revenue Bureau of Compliance Lien Section PO BOX 280948 Harrisburg PA 17128-0948 9 Commonwealth of Pennsylvania Department of Revenue Bureau of Compliance Clearance Support Department 281230 Harrisburg, PA 17128-1230 ATTN: Sheriff's Sales 10 United States of America Internal Revenue Service Technical Support Group William Green Federal Building Room 3259 600 Arch Street Philadelphia, PA 19106 _ 11 Domestic Relations Cumberland County P.O. Box 320 Carlisle, PA 17013 12 Tax Claim Bureau 1 Courthouse Square Carlise, PA 17013 13 Commonwealth of PA Department of Revenue Bureau of Compliance Department 280946 Harrisburg, PA 17128-0946 Attn: Sheriffs Sales 14 United States of America do United States Attorney for the Middle District of PA William J. Nealon Federal Bldg. 235 North Washington Avenue, Ste. 311 Scranton, PA 18503 15 United States of America do United States Attorney for the Middle District of PA Harrisburg Federal Building & Courthouse 228 Walnut Street, Ste. 220 Harrisburg, PA 17108-1754 16 . United States of America c/o Atty General of the United States U.S. Dept of Justice, Room 5111 950 Pennsylvania Avenue NW Washington, DC 20530-0001 17 K United States of America c/o Atty General of the United States U.S. Dept of Justice, Room 4400 950 Pennsylvania Avenue NW Washington, DC 20530-0001 Total Number of Pieces Total Number of Pieces Postmaster, Per (Name of receiving employee) The full declaration of value s required on all domestic and international registered mail. Thc maximum indemnity payable or the reconstruction of nonnegotiable documents and r Express Mail document reconstruction insurance is $500 per piece subject to additional limita ions for multiple pieces Listed by Sender Received at Post Office lost or damages in a single catastrophic occurrence. The maximum indemnity payable on Express Mail merchandise insurance is $500, but optional Express Mad Service merchandise is available for up to $5,000 to some, but not all countries. The maximum indemnity payable 's $25,000 for registered mail. See Domestic Mail Manual R900, $913, and S921 for limitations of coverage on insured and COD mail. See International Mail Manual for 17 limitations of coverage on international mail. Special handling charges apply only to Standard Mail (A) and Standard Mail (B parcels. PS Form 3877, August 2000 Complete by Typewriter, Ink, or Ball Point Pen McCABE, WESIBERG & CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID # 74770 MARISA J. COHEN, ESQUIRE - ID # 87830 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LAMANNA, ESQUIRE - ID # 310321 ANN E. SWARTZ, ESQUIRE - ID # 201926 JOSEPH F. RIGA, ESQUIRE - ID # 57716 JOSEPH I. FOLEY, ESQUIRE - ID # 314675 CELINE P. DERKRIKORIAN, ESQUIRE - ID # 313673 LENA KRAVETS, ESQUIRE - ID # 316421 CAROL A. DiPRINZIO, ESQUIRE - ID # 316094 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 (215) 790-1010 Wells Fargo Bank, N.A. Plaintiff v. Linda C. Jumper and Arthur Liebrum Defendants Attorneys for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY No. 14-2196 Notice of the Date of Continued Sheriff's Sale The Sheriff's Sale scheduled for December 3, 2014 at 10:00 A.M. in the above -captioned matter has been continued until February 4, 2015 at 10:00 A.M. Certificate of Filing On this date, a Notice of the Date of Continued Sheriff's Sale in the above -captioned matter was sent for filing with the Prothonotary of CUMBERLAND County. Certification of Service On this date, a Notice of the Date of Continued Sheriff's Sale was served by first-class mail, postage prepaid upon the following: Linda C. Jumper 226 Chestnut Street Mount Holly Springs, Pennsylvania, 17065 Date: IIIZO% Arthur Liebrum 309 Sandbank Road Mount Holly Springs, Pennsylvania, 17065 McCABE, WEISBERG & CO BY: [ ] Terrence J..'r s7 [ ] Edward D. Conway, Esq Andrew L. Markowitz, [ ] Marisa J. Cohen, Esq. [ ] Brian T. LaManna, Esq. [ ] Joseph F. Riga, Esq. [ ] Celine P. DerKrikorian, Esq. [ ] Carol A. DiPrinzio, Esquire Attorneys for Plaintiff , P.C. [ ] Marc S. Weisberg, Esq. [ ] Margaret Gairo, Esq. [ ] Heidi R. Spivak, Esq. [ ] Christine L. Graham, Esq. [ ] Ann E. Swartz, Esq. [ ] Joseph I. Foley, Esq. [ ] Lena Kravets, Esquire